https://www.taxtmi.com/acts?id=20714 The provision defines "resident of a Contracting State" as any person liable to tax in that State by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on income from sources in that State. For individuals with dual residency, a sequential tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases referred to the competent authorities for mutual agreement. en-us Mon, 28 Mar 2016 14:20:25 +0530 Thu, 28 Nov 2024 16:27:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=20714 The provision defines "resident of a Contracting State" as any person liable to tax in that State by domicile, residence, place of management, place of incorporation or similar criteria, excluding those taxable only on income from sources in that State. For individuals with dual residency, a sequential tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases referred to the competent authorities for mutual agreement. Act-Rules DTAA Mon, 28 Mar 2016 14:20:25 +0530 https://www.taxtmi.com/acts?id=20714